When will plaintiffs be able to submit their "theory of review" before a jury?

For these reasons, we reject plaintiffs' attempts to present these theories in this court. Subscribing to plaintiffs' "theory of review would allow a party to withhold a theory from the jury, by failing to request instructions, and then to obtain appellate review of the evidence and reversal of the judgment on a theory never tendered (or tendered in a different form) to the jury." (Null v. City of Los Angeles (1988) 206 Cal.App.3d 1528, 1535.) That is not the law.